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HMRC internal manual

Oil Taxation Manual

PRT: Foreign Fields - Double Taxation Relief

FA93\S194 provides for double taxation relief in relation to PRT chargeable on foreign fields under OTA83\S12. This is done by giving effect to ICTA88\S788 as if references therein included references to PRT. Double taxation issues will be addressed under double taxation treaty negotiations. The disclosure powers in ICTA88\S816 also apply to PRT.